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    Civil Interrogatories

    Uploaded by

    Christopher Struble
    This document contains a set of interrogatories from a plaintiff to a defendant regarding a lawsuit involving a forklift accident. The interrogatories request information such as the names and contact information of witnesses, the manufacturer and designer of the forklift, maintenance and safety records, and details of any investigations into the incident. The defendant is required to fully and truthfully answer the interrogatories under oath within 28 days.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd

    Civil Interrogatories

    Uploaded by

    Christopher Struble
    2K views4 pages
    This document contains a set of interrogatories from a plaintiff to a defendant regarding a lawsuit involving a forklift accident. The interrogatories request information such as the names and contact information of witnesses, the manufacturer and designer of the forklift, maintenance and safety records, and details of any investigations into the incident. The defendant is required to fully and truthfully answer the interrogatories under oath within 28 days.

    Original Description:

    Plaintiffs first set of interrogatories.

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    © Attribution Non-Commercial (BY-NC)

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    This document contains a set of interrogatories from a plaintiff to a defendant regarding a lawsuit involving a forklift accident. The interrogatories request information such as the names and contact information of witnesses, the manufacturer and designer of the forklift, maintenance and safety records, and details of any investigations into the incident. The defendant is required to fully and truthfully answer the interrogatories under oath within 28 days.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    2K views4 pages

    Civil Interrogatories

    Uploaded by

    Christopher Struble
    This document contains a set of interrogatories from a plaintiff to a defendant regarding a lawsuit involving a forklift accident. The interrogatories request information such as the names and contact information of witnesses, the manufacturer and designer of the forklift, maintenance and safety records, and details of any investigations into the incident. The defendant is required to fully and truthfully answer the interrogatories under oath within 28 days.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
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    This document appears to be a set of interrogatories related to a legal case involving a forklift accident. The interrogatories are requesting detailed information from the defendant to help understand the circumstances surrounding the incident.

    This document contains a plaintiff's first set of interrogatories propounded to a defendant. Interrogatories are written questions issued in a lawsuit to elicit facts or admissions from the opposing party. The purpose is to obtain information to aid in the litigation of the case.

    The interrogatories are requesting information such as the names and contact details of witnesses, maintenance records of the forklift, prior complaints or injuries related to the forklift, investigation details after the incident, and photographs of the forklift involved.

    Page

    This form may be different from your state or county. Please refer to the rules in your jurisdiction. DaytonParalegals is
    not responsible for irresponsible parties submitting the form on a “AS IS” basis. Check your Font and Size.

    COURT OF COMMON PLEAS


    ___________________ COUNTY, OHIO

    __________________________________________________
    )
    ______________________, ) Case No. _____
    Plaintiff, ) (Judge ___________________)
    vs. ) PLAINTIFF'S FIRST SET
    ______________________, ) OF INTERROGATORIES
    Defendant. ) PROPOUNDED TO
    ) DEFENDANT
    )
    __________________________________________________

    Pursuant to Rule 33 of the Ohio Rules of Civil Procedure, Defendant is required to answer the
    following interrogatories fully, in writing, and under oath, and to serve a copy of the Answer upon
    the Plaintiff within twenty-eight (28) days from the date of receipt.

    A. Where the identity of a person is requested, state full name, home address, and also business
    address, if known.

    B. Unless otherwise indicated, these interrogatories refer to the time, place and circumstances and
    occurrences set forth in Plaintiff's Complaint.

    C. Where knowledge or information in possession of a party is requested, such a request includes


    knowledge of the party's agents, representatives, and employees. Where answer is made by a
    corporate Defendant, state the name, address and title of the person supplying the information as
    well as the source of this information.

    D. The pronoun ''you'' refers to the party to whom these interrogatories are addressed and the
    persons mentioned in paragraph C above.

    E. You are under a duty to reasonably supplement your responses to these interrogatories, in
    accordance with Rule 26(E) of the Ohio Rules of Civil Procedure.

    1. State the names, addresses, telephone numbers, and positions with the Defendant of
    each person who provided information for the answers of these interrogatories.

    ______________________

    ______________________

    2. State the job title and job description of Plaintiff ___________________ with
    Defendant on or about [date].

    ______________________
    Page
    This form may be different from your state or county. Please refer to the rules in your jurisdiction. DaytonParalegals is
    not responsible for irresponsible parties submitting the form on a “AS IS” basis. Check your Font and Size.

    ______________________

    3. State the name, address, and telephone number of each person known to Defendant
    who witnessed in whole or in part the incident that occurred on
    ____________________[date], which is described in Paragraph 7-10 of the Complaint
    filed herein.

    ______________________

    ______________________

    4. State the name, address, and telephone number of any person known to Defendant
    who submitted to Defendant any written complaint, warnings, comments, or any other
    statements relating in any way whatsoever to the design, safety features or defects in
    the fork lift truck referred to in paragraph 10 of the Complaint.

    ______________________

    ______________________

    5. State the name, address, and telephone number of any person known to Defendant
    who made verbal complaints, comments, or other statements regarding the design,
    safety features, or defects in the fork lift truck referred to in paragraph 10 of the
    Plaintiff's Complaint.

    ______________________

    ______________________

    6. State the name, address, and telephone number of the entity which manufactured the
    fork lift truck referred to in paragraph 10 of Plaintiff's Complaint.

    ______________________

    ______________________

    7. State the name, address, and telephone number of the entity which designed the fork
    lift truck referred to in paragraph 10 of Plaintiff's Complaint.

    ______________________

    ______________________

    8. When did Defendant purchase, lease, or otherwise acquire the fork lift truck referred
    to in paragraph 10 of Plaintiff's Complaint?

    ______________________
    Page
    This form may be different from your state or county. Please refer to the rules in your jurisdiction. DaytonParalegals is
    not responsible for irresponsible parties submitting the form on a “AS IS” basis. Check your Font and Size.

    ______________________

    9. Identify in detail each modification or alteration made to the fork lift truck referred
    to in paragraph 10 of Plaintiff's Complaint following the date of acquisition.

    ______________________

    ______________________

    10. State the name, address, and telephone number of any person known to Defendant
    who sustained injury prior to ____________________[date], arising out of the
    operation of the fork lift truck referred to in paragraph 10 of Plaintiff's Complaint.

    ______________________

    ______________________

    11. Has Defendant ever had a regular maintenance schedule for the fork lift truck
    referred to in paragraph 10 of Plaintiff's Complaint? If so, set forth that maintenance
    schedule.

    ______________________

    ______________________

    12. On ____________________[date], were there any written warnings regarding


    proper operation of the fork lift truck referred to above? If so, please set forth the text
    of each such written warning.

    ______________________

    ______________________

    13. State the name of plaintiff's immediate supervisor on


    ____________________[date].

    ______________________

    ______________________

    14. Did Defendant conduct an investigation or inspection of the fork lift truck
    following the incident described in paragraph 7-10 of the Complaint?

    ______________________

    ______________________
    Page
    This form may be different from your state or county. Please refer to the rules in your jurisdiction. DaytonParalegals is
    not responsible for irresponsible parties submitting the form on a “AS IS” basis. Check your Font and Size.

    15. If the answer to the preceding interrogatory is in the affirmative, please state the
    name, address, and telephone number of each individual who participated in said
    investigation or inspection.

    ______________________

    ______________________

    16. Does Defendant have any photographs of the fork lift truck referred to in paragraph
    10 of the Complaint?

    ______________________

    ______________________

    ______________________

    [Attorney signature]

    ______________________

    ______________________

    ______________________

    [Firm name, address and phone number]

    Attorney for Plaintiff

    I hereby certify that a copy of the foregoing Interrogatories were served upon counsel for Plaintiff
    and upon all other counsel of record by regular U.S. mail, postage prepaid, this _____[date] day of
    ____________________, 20_____[month and year].

    ______________________

    [Attorney Name]

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